Lobbying Activity
Response to Circular Economy Act
5 Nov 2025
The U.S. Cotton Trust Protocol welcomes the opportunity to contribute to the Commissions public consultation on the Circular Economy Act. Our mission is to measure and verify sustainable cotton production practices at the farm level in the U.S., providing brands and retailers with transparent, verifiable data, and driving continuous improvement in virgin cotton's environmental and social footprint. While based in the U.S., our framework offers a practical model for how the EU can achieve the Acts objectives by integrating robust, third-party verified sustainability programs into its regulatory architecture. We strongly believe that transparent, verifiable data strengthens market confidence in sustainable materials, supports circular business models, and reduces misleading claims. Our program offers field level, third-party verified, quantifiable data on key U.S. cotton sustainability metrics: water use, energy efficiency, land use, soil health, soil carbon, greenhouse gas emissions. Brands and retailers, many operating in the EU, use these metrics to meet sustainability requirements, gaining reassurance that the cotton fiber part of their supply chain is sustainably sourced with improved environmental and social risks. This visibility is essential for brands to integrate sustainable sourcing into their circular economy strategies, enabling the creation of products with an improved environmental footprint and fostering a more circular supply chain through informed material choices. Based on our experience, we encourage the Commission to consider the following recommendations: To address the fragmented single market for secondary raw materials, we advocate for the Act to establish comprehensive, standardized, and data-driven indicators for circularity. The Trust Protocol's proven system for collecting, verifying, and reporting environmental metrics, alongside our comprehensive supply chain traceability solution, offers a blueprint for developing similar robust, verifiable data systems for all secondary raw materials, simplifying compliance and accelerating circular practices. To unlock the full potential of recycled materials and address the significant barrier of origin opacity, we recommend the Act mandate robust traceability for recycled fibres, leveraging the Digital Product Passport. This will enable brands to confidently integrate recycled content by providing known provenance, preventing the unwitting introduction of restricted sources (e.g. cotton from specific regions), and allowing recycling operators to identify and segregate materials that meet specific criteria. This fosters transparent and traceable circular material flows, essential for the Act's success and for brands to feed industrial and consumer waste back into recycling, much like the known provenance provided by programs such as the Trust Protocol for virgin materials. Given the global nature of supply chains and the Act's aim to reduce market fragmentation, we urge the Act to recognize all credible sustainability programs that support EU circularity objectives, like the Trust Protocol. This would help reduce duplication in reporting, harmonize data collection across global supply chains, and lower compliance costs for companies operating in multiple jurisdictions. To boost the supply and demand for quality secondary raw materials and achieve climate neutrality, the Act should adopt a holistic lifecycle approach. Minimizing upstream environmental impact is crucial for overall circularity, not solely focusing on end-of-life. Policies should incentivize verifiable sustainable sourcing across all material inputs (virgin and recycled) and encourage "design for longevity" and "design for recyclability" from the outset. Finally, we urge a clear implementation to ensure predictability for industry, incentivize early action by ambitious actors, including non-EU stakeholders who contribute to the sustainability and circularity of strategic value chains.
Read full responseResponse to Digital Product Passport (DPP) service providers
9 Dec 2024
In order for the Digital Product Passports (DPPs) to be a credible source of information, it is important that they privilege the best possible data available. When recent direct data is available, this should be made clear to the audience and preferred to database information. We would therefore like to ask for up-to-date, reliable third-party verified data to be highlighted, and for database information to be clearly marked as such in a way that is visibly less attractive. The U.S. Cotton Trust Protocol is the voluntary sustainability program for U.S. cotton growers and traceability platform for all U.S. Cotton. Its mission is to create a sustainable standard for U.S. Cotton that is data-powered, traceable by design, and generates positive impact through the global cotton value system from farms to finished product. The Trust Protocol is dedicated to promoting sustainability and transparency in the cotton value chain, notably by providing comprehensive, third-party verified farm-level data which can be integrated into the DPP. We collect robust, science-based data directly from growers, to inform key sustainability metrics like water use, energy efficiency, land use, soil health, soil carbon and greenhouse gas emissions. We are at present the only cotton programme with a comprehensive dataset providing this level of information. We think it is paramount for the consumer and value chain to be made aware when the data in the DPP is not directly supplied and collected year-on-year in the value chain.
Read full responseResponse to Revision of EU rules on textile labelling
28 Sept 2023
The U.S. Cotton Trust Protocol welcomes the opportunity to contribute to the European Commissions Call for Evidence regarding the revision of the Textile Labelling Regulation. The Trust Protocols mission is to bring quantifiable and verifiable goals and measurement to the key sustainability metrics of U.S. cotton production with a vision where transparency is a reality and continuous improvement to improve our environmental footprint is the central goal. We support the direction taken by the European Commission in trying to improve textile products sustainability and circularity. We appreciate the efforts made to inform consumers by providing transparent, precise, and accessible details regarding products fiber composition. The present Call for Evidence proposes comprehensive harmonization across the EU market. We believe that extensive harmonization would benefit consumers by enhancing information access and reducing compliance costs, thereby enhancing market integration and efficiency. Aligned with the goals highlighted in the Call for Evidence, the U.S. Cotton Trust Protocol believes that the use of third-party-verified voluntary sustainability labels should be encouraged as a valuable tool to complement labelling requirements mandated by the revised Regulation. Brands and retailers have committed to reducing their environmental impact, and voluntary certification schemes have invested in providing data that shows progress towards these ambitious goals. Taking into account the requirements outlined in the Directive on substantiating Green Claims, certification schemes should be encouraged to feature on textile labels. In alignment with the Ecodesign for Sustainable Products Regulation, Digital Product Passports (DPPs) are a promising tool to facilitate the dissemination of more complex information conveyed by certification schemes. The U.S. Cotton Trust Protocol measures greenhouse gas emissions, energy efficiency, water use efficiency, land use, soil conservation and soil carbon retention. DPPs could be the vehicle through which consumers learn more about ongoing improvements in those domains. There is no doubt that textile waste is an important issue to address. Some reports put estimates at 92 million tons of waste generated by the fashion industry annually. Waste whether in landfills or as byproducts of the laundry process should be addressed. Waste that does not biodegrade (such as microplastics) generates an additional threat to the environment. As emphasized by the UN, the industry is a contributor to around 35% of primary microplastics pollution in oceans (equivalent to 190,000 tons annually). Natural fibers like cotton are expected to degrade much faster within a variety of aquatic environments compared to, for example, polyester microfibers that are projected to last in the environment for longer periods of time, with potentially harmful effects on animals and ecosystems. The U.S. Cotton Trust Protocol believes labels could be an important tool to provide consumers with transparent laundry and end-of-life information, highlighting the benefits and threats associated with product use and disposal based on their fiber composition and biodegradability. See attachment for reference to quoted studies.
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